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NUNAVUT IMPACT REVIEW BOARD MARY RIVER PHASE 2 PROPOSAL BAFFINLAND IRON MINES CORPORATION NIRB File. No. 08MN053 BAFFINLAND's

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NUNAVUT IMPACT REVIEW BOARD MARY RIVER PHASE 2 PROPOSAL BAFFINLAND IRON MINES CORPORATION NIRB File. No. 08MN053 BAFFINLAND's NUNAVUT IMPACT REVIEW BOARD MARY RIVER PHASE 2 PROPOSAL BAFFINLAND IRON MINES CORPORATION NIRB File. No. 08MN053 BAFFINLAND’S RESERVATION OF OBJECTION TO THE MITTIMATALIK HUNTERS AND TRAPPERS ORGANIZATION’S REQUEST TO FILE NEW REPORTS - EXHIBITS 63, 64, 65, 66 AND 67 1. During its presentation at the Phase 2 Proposal Public Hearing held January 25 to February 6, 2021, the Mittimatalik Hunters and Trappers Organization requested to file several technical reports. The Nunavut Impact Review Board marked these documents as Exhibits 63-67 for identification. Baffinland reserved its objection to the entry of Exhibits 63-67 as evidence in the proceeding. 2. After considering the documents, Baffinland determined that it had previously been provided with copies of Exhibits 63, 64 and 66 at the September 2020 Technical Meeting; however, Baffinland had not previously reviewed Exhibits 65 and 67. 3. Baffinland has no objection to the entry of Exhibits 63-67. In response to the two new documents, Exhibits 65 and 67: (a) Baffinland has submitted a technical review to Exhibit 67 – “Cortisol Levels in narwhal (Monodon monoceros) blubber from 2000-2019” (NIRB Document No. 332989) as part of its written responses to questions filed March 22, 2021. This review is included under CR-5, Attachment 1: Golder Review of Paper on Cortisol Levels in Narwhal (p. 218/339). (b) Baffinland has prepared a very brief response to Exhibit 65 – “Trace metals and Persistent Organic Pollutants concentrations in Narwhals from Eclipse Sound” 2 (NIRB Document No. 332993). A copy of that response, authored by Christine Moore of Intrinsik Corp., is attached. Dated March 23, 2021 “Lawson Lundell LLP” ___________________________________ Lawson Lundell LLP Solicitors for Baffinland Iron Mines Corporation Memo Date: March 22, 2021 To: Megan Lord-Hoyle; Baffinland From: Christine Moore, Intrinsik Corp. cc : Re: MHTO 2010204-08MN053 Trace Metals and Persistent Organic Pollutants Concentrations in Narwhal from Eclipse Sound – Preliminary Report - Comments Community-based monitoring and the data collected in this study related to trace metals are important for characterizing metals levels in narwhal in Eclipse Sound in 2019 and provide valuable insight into the metal concentrations in narwhal. Baffinland appreciates the sharing of this data and looks forward to seeing the final report. Baffinland would welcome access to the data once the analysis is finished, in order to incorporate it into the understanding of environmental baseline at the time of the Phase 2 project, if approved. Differences in mercury concentrations in narwhal between the 1970’s and 2019 were identified in the study. The authors compared the 2019 data for narwhal collected in Eclipse Sound, to those from earlier studies conducted in the Pond Inlet area in 1977 (Fallis unpublished) and 1979 (Wagemann et al 1983) summarized in Wagemann and Muir, 1984. The 2019 study by ArctiConnexion specify that ageing results for the narwhal were not available at the time the preliminary report was prepared; we agree with the authors that this will be important information to consider in the final report. Other information including a comparison of the sampling methods will be important in the data interpretation as other research suggests that mercury concentrations can change within muscle tissues depending upon the depth of the sample in the narwhal skin (Wagemann and Kozlowska, 2005). Given the prevalence of mercury in the Arctic environment, an increased understanding of the baseline concentrations in the marine environment will provide valuable insight in the identification of changes over time associated with long range deposition. The author also draws some comparisons between the Mary River mine and some mining operations in other locations, and we wanted to note the differences between Baffinland’s operations and these other facilities. The study mentioned by Ferreira and Leite (2015) relates to a mining operation in Brazil, wherein a life cycle assessment of an iron ore mine was conducted, which suggest that releases of specific metals into the air and water are linked to impacts on the ecosystem and on people. The Page | 1 Brazilian mine operation discussed in this publication is a complex operation involving mining, processing and pelletizing activities, which are dissimilar to the Mary River mine and port operations. The operations in Brazil include mining, followed by processing of ore which involves crushing, milling and flotation cells, which result in the production of tailings and concentrate. The iron ore concentrate undergoes a secondary grinding process involving additional equipment and chemical processing. The Baffinland Mary River mine only involves the mining and processing of ore using a crusher. There is no milling, flotation, creation and storage of tailings, secondary processing using chemical agents, or pelletizing (which would result in increased releases to air). As a result of these differences, the environmental impacts associated with the Brazilian mining operation can not be used as an example for potential impacts to the environment related to the Mary River mine. A second study cited (Cagnin et al, 2017) is also related impacts associated with Brazilian mining. This study examines the impacts of historical mining in a specific region in Brazil (dating from the 1700s) and existing mining operations, which include both iron ore and gold mining. Again, this issue differs from the Mary River mine, in that there have been centuries of mining in this area of Brazil, dating back to the 1700s, and there are multiple mines in this particular region which have been operating for some time. Baffinland looks forward to seeing the final report of this study, and appreciates the effort taken in the sampling and analysis, as well as the community involvement and interest in the study. References Cagnin, R.C., Quaresma, V.S., Chaillou, G., Franco, T., and Bastos, A.C. (2017). Arsenic enrichment in sediment on the eastern continental shelf of Brazil. Science of The Total Environment 607–608, 304–316. Ferreira, H., and Leite, M.G.P. (2015). A Life Cycle Assessment study of iron ore mining. Journal of Cleaner Production 108, 1081–1091. Fallis (unpublished) cited in Wagemann, R., & Muir, D. C. (1984). Concentrations of heavy metals and organochlorines in marine mammals of northern waters: overview and evaluation. Canada: Western Region, Department of Fisheries and Oceans. Wagemann, R., N.B. Snow, A. Lutz, and D.P. Scott. 1983. Heavy metals in tissues and organs of the narwhal (Monodon monoceros). Can. J. Fish. Aquat. SC1. 40(Suppl. 2): 206-214. Wagemann, R., & Muir, D. C. (1984). Concentrations of heavy metals and organochlorines in marine mammals of northern waters: overview and evaluation. Canada: Western Region, Department of Fisheries and Oceans. Wagemann, R., & Kozlowska, H. (2005). Mercury distribution in the skin of beluga (Delphinapterus leucas) and narwhal (Monodon monoceros) from the Canadian Arctic and mercury burdens and excretion by moulting. Science of the Total Environment, 351, 333-343. .
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